Anti-money laundering laws only apply to firms that meet the  Bank Secrecy Act definition of a “ Ffinancial  Iinstitution.”  See the following link for a definition of  that term,  (http://www4.law.cornell.edu/uscode/31/5312.html).  Investment advisers are not included in the list of BSA "Financial Institutions."  However, in a Notice of Proposed Rule Making issued on May 5, 2003 (68 F.R. 23646, Vol. 86) FinCEN took the position that the Bank Secrecy Act authorizes the Treasury Department to expand the list of BSA "Financial Institutions," and issued a Notice of Proposed Rule Making that would designate investment advisors as "Financial Institutions" and require them to implement Anti-Money Laundering Programs.  The Proposed Rule was never made a Final Rule, and the Proposed Rule was formally withdrawn by FinCEN on November 4, 2008.  (73 F.R. 65568, Vol. 214).  It seems clear from FinCEN's Notice of Withdrawal of the Proposed Rule, though, that FinCEN is still considering including investment advisors as "Financial Institutions" and that it is likely to issue a new Proposed Rule to include them, possibly this year or early next year..